This blog is co-authored by Eric Geldenhuys, a candidate attorney.

The proposed amendments to South Africa’s Civil Aviation Regulations (CARs) and Technical Standards (CATS) are open for public comment until 2 February 2026. They modernise terminology and meteorology, streamline maintenance and safety management, refine aviation security, and clarify medical and public‑health protocols.

Airworthiness and maintenance (CARs 24, 43 and 91.9)

CARs 24 replaces the “currency fee” with a formal Authority to Fly renewal process, specifying application timing, fees, and decision criteria, including a backstop for renewals missed by more than 90 days.  CARs 43 and 91.9 clarify maintenance programme responsibility and permit Director‑approved time‑between‑overhaul (TBO) variations, including through condition monitoring.  This allows certain private piston aeroplanes (≤5,700 kg MTOW) to operate beyond standard TBOs under an approved condition-monitoring programme, addressing industry concerns about strict TBO limits.  Any variation must be documented in the maintenance or condition-monitoring programme per CATS 43.  For more details, see our blog of 20 October 2025: Aviation maintenance regulations remain in force | Financial Institutions Legal Snapshot

Operational safety management (CARs 91.12 and 127; CATS 127)

CARs 91.12 expands Safety Management System (SMS) obligations, introduces mandatory flight data analysis for certain aircraft, and creates a Fatigue Risk Management System (FRMS) pathway. Flight data analysis is required for specific large aircraft with Certificates of Airworthiness issued from 1 January 2027.  Operators must implement systems for managing safety data per CARs 140. CARs 127 and CATS 127 detail the FRMS, which must be integrated with the SMS and requires a Director-approved trial of up to 36 months to demonstrate safety outcomes.Offshore training must now include route qualification, flight preparation, alternate heliport criteria, and the use of HUMS to validate critical systems.

Aviation security (CARs 109 and 110)

CARs 109 modernises the framework by moving procedural detail into CATS 109 and updating training categories for Aviation Security Training Organisations.  It adds cyber‑security obligations, including identifying critical ICT systems and data, adopting security‑by‑design and supply‑chain security, ensuring network separation, maintaining testing and response procedures, and notifying cyber incidents within 48 hours.  CARs 110 refreshes screener certification and screening‑organisation approvals with references to CATS 110, clarifying permitted functions, audit attendance, renewal timing and career paths.

Unmanned aircraft SMS scope (CARs 140 and 101)

CARs 140 clarifies which organisations must run an SMS and removes the inapplicable ROC reference in 140.01.1 to avoid mis‑scoping SMS duties.  The motivation recognises ICAO timelines to November 2026 and situates unmanned operations under the UASOC framework in CARs 101.

Flight procedure design approvals (CARs 173)

CARs 173 adds a requirement for a formal Department of Transport mandate before approval, aligning with ICAO Annex 11 on State designation and ensuring accountability alongside technical competence and safety.

Meteorological services (CARs 174; CATS 174)

Part 174 is restructured to align with ICAO Annex 3 Amendment 82 and PANS‑MET, clarifying roles, automated observations, reporting, TAF dissemination and RCC support functions. SA‑CATS 174 updates technical standards and formats to match Annex 3 and PANS‑MET for consistency.

Personnel and public health (CATS 64, 67 and 113)

CATS 64 harmonises cabin‑crew definitions used in licensing and operations for consistent training and line operations. CATS 67 introduces alcohol and substance use, ENT, and Botulin Toxin protocols, with screening, assessment, grounding and return‑to‑duty pathways, including random toxicology and supervised‑duty restrictions. CATS 113 requires aerodrome operators to release personal information for notifiable‑disease contact tracing, subject to POPIA.

If you need further details on the amendments, please contact Kiasha Nagiah and Eric Geldenhuys.